We have heard a lot from the media on active shooter events throughout the U.S., but how many of these include healthcare facilities? The Homeland Security and the FBI define “active shooter” as “an event where one or more persons actively engage in killing or attempting to kill people in a populated area.” Statistics show active shooter incidents involving healthcare facilities are less common than other events, but they can occur, so planning may save lives.
A look at the calendar tells us that we only have a short time left in 2018. That means many practices will be looking to complete their Security Risk Assessments in order to either qualify for the 2018 Merit-based Incentive Payment System (MIPS) or to simply fulfill their obligations to comply with the HIPAA Security Rule.
2017 was the first year for participation in the Merit-based Incentive Payment System (MIPS), a Quality Payment Program (QPP) implemented by CMS, to award or penalize participating clinicians with regard to future Medicare reimbursements based upon reporting under four categories:
It’s been more than twenty years since the 1997 revisions to Evaluation and Management guidelines, which focus mainly on physical examination. The 2019 proposed changes provide practitioners a choice in the basis of documenting E/M visits; alleviate the burdens, and focus attention on alternatives that better reflect the current practice of medicine. The implementation of electronic medical records has allowed providers to document more information, yet repetitive templates, cloning, and other workflows have pushed the envelope on compliance in documenting the traditional elements of the visit.
Many Alabama providers participated in the Quality Payment Program in 2017, under MIPS (Merit Based Incentive Program). A handful participated in a MIPS APM (Alternative Payment Model), which is a baby step towards alternative payments, but still left the participants free from downside risks. As we pass the half-way point for the 2018 performance period, exploring risk bearing programs is on the rise.
As today’s healthcare drive pushes practices even further down the path of pay for performance versus the older models of pay for volume, administrators and executives throughout healthcare are researching and implementing ideas to provide an overall better experience for patients.
At the core of the Affordable Care Act (ACA) is the three-legged stool: (1) insurance reforms; (2) the individual mandate; and (3) premium and cost-sharing subsidies. Removal of any one of these legs could destabilize the ACA. The ACA established insurance marketplaces in every state to provide access to ACA compliant private health insurance coverage (Qualified Health Plans) in the individual and small group markets. The ACA provides premium subsidies on a sliding scale for persons with incomes up to 400% FPL for the purchase of an individual policy on the marketplace exchange. It also provides cost-sharing subsidies for persons with incomes below 250% FPL. Prior to the implementation of the ACA, manual rating was typically used by insurers for rate-making in the individual and small group markets and exclusions from coverage for pre-existing conditions were common. Age-based rates were typically 5:1. The insurance reforms in the ACA are largely directed at the small group and individual markets (e.g., guaranteed issue/renewal, no preexisting condition limitations, adjusted community rating capped at a 3:1 ratio for age). Standardization of benefits is achieved by requiring coverage for ten essential health benefits (EHBs) and certain preventive services which in the latter case services must be provided without cost-sharing.
As we finalize 2017 participation in the Merit Based Incentive Program, most of us focused on improved performance in quality since the category carried the highest weight of 60%. Those who had previous success in Meaningful Use found the Advancing Care category easy to address. The Practice Improvement category is new and somewhat vague, but many practices were already performing tasks that qualified as an improvement activity. It is important to document the approach to improvement and track success because this category is subject to audit in the future.
An Oklahoma physician agreed on August 28, 2017 to pay the government $580,000 to resolve allegations that he violated the False Claims Act by submitting claims to the Medicare program for services he did not provide or supervise. According to the government, the physician allowed a company that employed him and in which he had an ownership interest to use his NPI numbers to bill Medicare for physical therapy evaluation and management services that he did not provide or supervise. The government further alleged that after he separated from the company and deactivated his NPIs associated with the company, he reactivated those NPIs so that the company could use them to bill Medicare for services he neither performed nor supervised.
On June 20th, CMS issued its proposed rule for year 2 of the Quality Payment Program (QPP) under Medicare Access and CHIP Reauthorization Act of 2015( MACRA). Comment period ends August 20.
As we approach the beginning of summer, our minds are likely not on summer vacation. The process of assessing our electronic medical record vendor, absorbing the details of MIPS, and making the decisions on how to prepare, is overwhelming for small practices. The transition to value based medicine has been evolving over the last 10 years in stages; adopting electronic health record, Quality Reporting, and Meaningful Use. Many administrators and physicians did not realize the importance of each project; from choosing the right EMR, to implementing it properly, therefore achieving best practice workflows.
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